Tuesday, March 3, 2009

2008 Dust Explosions and Fires Overview

The Combustible Dust Policy Institute found through researching media accounts in 2008 that over 150+ combustible dust related fires and explosions occurred in the manufacturing, non-manufacturing and utility sectors in the United States. Over 30% of these incidents are repeats of prior fires and explosions that fire departments are responding to. Subsequently, these reoccurring incidents mostly go unnoticed by OSHA, unless there are at least three injuries or one fatality.

The current OSHA Combustible Dust National Emphasis Program (NEP) directive does not address the majority of national industries (NAICS) where incidents are frequently occurring. For example, over 60% of incidents in 2008 occurred in national industries not listed in Appendix D-1 and D-2 of the NEP. Too much emphasis and resources is being directed toward the OSHA Dust NEP, when the majority of incidents are occurring in national industries not referenced in the NEP.

To further complicate the situation, the Chemical Safety Board Combustible Dust Hazard Study did not include in the profile of affected industries, the Paper, Textile, and Non-Manufacturing subsectors as industries where a combustible dust hazard exists. For example, in 2008, over 22% of incidents occurred in these subsectors. Without this important information, OSHA did not include paper national industries in the NEP. Over 10% of combustible dust related incidents in 2008 occurred in paper national industries.

In contrast, over 7% of incidents in 2008 occurred in the rubber/plastics subsector, where these national industries were referenced 90% of the time in the OSHA Dust NEP. A NAICS listing in the NEP does not guarantee the probability of occurrence will be lessened. For instance, the national industry NAICS: 326150/Urethane and Other Foam Product Manufacturing, the U.S Census Bureau lists over 433 firms in the USA. In 2008, OSHA inspected 9% (37) of these facilities with only three inspected for an emphasis on combustible dust.

For 2008, media accounts of combustible dust related fires and explosions occurred in thirty-six states. The states with 10 more or more incidents included Ohio (12), Illinois (10), Maine (10), Pennsylvania (10), and Iowa (10). Injuries occurred in 12% of the incidents. Of the total incidents reported by the media in 2008, 20% were combustible dust explosions.

Reviewing the the grain sector, through media accounts, over 50 combustible dust related fires and explosions occurred in 2008 with over 30% (15) were dust explosions. The adverse economic impact from dust explosions in this sector was much greater than the economic impact from explosions in the manufacturing sector. A question does arise if it makes good sense to model the current pending combustible dust legislation after the OSHA Grain Facility Standard, when so many injuries and economic damage is occurring from dust explosions similar to what’s happening in the manufacturing sector?

This brief overview of combustible dust related incidents in 2008 will hopefully provide all stakeholders additional insight into the complexity of combustible dust hazards in the workplace. The current occupational health and safety regulatory framework does not currently address the magnitude of the problem that encompasses all the national industries where incidents are repeatedly occurring throughout the manufacturing and non-manufacturing sector.


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